Lorraine Janet Irlam,
Registered Clinical Counsellor
(Also known as “My Therapy” or “My Therapy Online”)
My Therapy, the licensed provider of PrivacEmail, is committed to protecting the privacy of people whose personal information is held. All clients of our services, professional helpers, and visitors to our web sites must be treated with personal human care, outstanding ethics, and integrity. We undertake to honour or exceed the legal and ethical requirements of information privacy that apply in Canada through responsible information management practices. Any personal information you provide is collected, used and disclosed in accordance with the ethical codes of the counselling profession and the Personal Information Protection and Electronic Documents Act of Canada.
What is Personal Information?
Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:
* Last name
* First name
* Street Address (home)
* Telephone number
* E-mail address
* Credit card information
* Province (State)
* Postal (Zip) Code
* Telephone Area code
* Time Zone
* Best times to call
* How clients found out about our services
* Visits to our web sites
Personal information also includes:
* opinions, evaluations, comments, social status, or disciplinary actions; and
* employee files, credit records, loan records, medical/counselling records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs)
What kind of information is being collected?
If you visit a PrivacEmail web site to browse, read pages, or download information, we will gather and store certain information about the visit. The following information is automatically collected and stored: The Internet Protocol Address and domain name used. The Internet Protocol address is a numerical identifier assigned either to your Internet service provider or directly to your computer. This address can be translated to determine
* the domain name of your service provider (e.g. gov.bc.ca, xcompany.com or yourschool.edu);
* The type of browser and operating system;
* The date and time of the visit; and
* The web pages or services accessed.
Information collected automatically is used for purposes such as assessing system performance, improving web services and web site management. My Therapy does not use this data to determine your identity unless required to do so as part of an internal investigation or other law enforcement purpose.?
Information Collected Directly From You
My Therapy does not collect personal information about you unless you voluntarily provide it to use specific services. Personal information collected, used, disclosed and retained by My Therapy will only be used by authorized staff to fulfill the purpose for which it was originally collected, or for a use consistent with that purpose unless you expressly consent otherwise.
What safeguards are in place?
PrivacEmail protects your personal information by making careful security arrangements against such risks as unauthorized access, collection, use, disclosure or disposal. Security measures have been integrated into the design, implementation and day-to-day operating practices as part of our continuing commitment to the protection of personal information it holds.
The PrivacEmail site uses the industry standard 128-bit SSL (secure socket layer) encryption. In addition, all data stored in our databases are encrypted.
In addition to our encryption standards, your PrivacEmail account information is password-protected so that only clients, their counsellors, the counsellors’ supervisors, and, only as required, PrivacEmail technical staff, have access to this personal information.
Your responsibilities in the protection of your privacy:
We urge you NOT to disclose your PrivacEmail password to anyone, or to allow another person to access the PrivacEmail system while you are still logged in.
We urge you to logout after each use of the PrivacEmail site, and to clear your browser’s cache. This is also known as clearing your recent browsing history. (Please refer to your browser’s help menu if necessary.) This helps keep your personal information safe, and is particularly important if others may be using the same computer after you.
We advise you to be aware of the security issues related to downloading and storing files to your local computer or to a portable storage device, and if you are not aware of the risks, to avoid doing so. Once a file is stored on your local computer or on a portable storage device, it is unencrypted, and you become fully responsible for safeguarding that file.
Please be aware that computer viruses, malware, and even legitimate software products exist that are capable of recording keystrokes. It is good computing practice to always ensure that your computer is running up-to-date antivirus software.
We do not warrant the privacy of confidential material that becomes insecure because of user negligence or actions that users may take or that is a result of software that PrivacEmail did not supply. Examples of security breaches that we do not warrant include, but are not limited to:
* leaving confidential material on a computer screen for others to see
* storing confidential material on the local computer or a portable storage device
* use of monitoring software (for example, by an employer)
While we strive to protect users’ personal information, no data transmission over the Internet is guaranteed to be 100% secure. Thus, PrivacEmail cannot ensure or warrant the security of any information during transmission to or from our site, and users submit information to us at their own risk. However, we do our best to ensure the highest level of security on our systems.
Use of User Personal Information
The primary use of clients’ personal information is the provision of professional online counselling, including the support of PrivacEmail licensors’ provision of online counselling.
Clients Urged to Update Information
Clients are asked to update their address, telephone number, and e-mail address, whenever such changes occur. Failure to do so releases us from our ethical/legal obligation to warn of life threatening situations.
How long is information retained?
The length of retention will vary in relation to the nature of the service. PrivacEmail will securely store all records containing personal information, including online counselling transcripts, for a period of seven years after your counselling ends.
How can I access and correct my personal information?
You can review any personal information collected about you by simply requesting it in writing. You may request changes or annotate your personal information if you believe it to be inaccurate by submitting a written request describing the error.
Links to other sites
We have no control over the third parties whose hyperlinks we allow on our site. These third parties may change their web site content without notice. Clients or visitors who link to any other site do so at their own risk and Therapy Online will not be responsible or liable for any damages in connection with linking.
A cookie is a small file stored on your computer by your web browser when using some Internet sites. The PrivacEmail system uses temporary cookies to facilitate your transactions. These cookies exist in your browser’s temporary memory only and are deleted when you close your browser.
Distribution of Unsolicited Information
The management of PrivacEmail will not send clients any unsolicited information, including e-mail, except as follows:
1. When users establish and use their secure PrivacEmail account, they will receive an “e-mail notification” which is a non-secure e-mail notification message whenever a new Private Conversation message is sent to them. These e-mails do not mention the words “counselling” or therapy”.
2. Occasionally, the management of PrivacEmail may send unsolicited notices as a Private Conversations message. These notices, if sent, will allow us to provide counselling follow-up or request evaluation of our services, or to announce important service changes, new features, technical updates and news about other Therapy Online products and services. Therapy Online will not send unsolicited messages regarding any third party commercial offers or advertisements.
Additional Information in accordance with the Personal Information Protection Act (PIPA) of British Columbia
1. The counsellor named above is responsible for compliance with the Personal Information Protection Act and has adopted these policies and procedures in support of that legislation, including a complaint process.
2. The counsellor will comply with these policies and procedures and, in doing so, the counsellor will consider what a reasonable person would consider appropriate in similar circumstances.
3. The counsellor is responsible for all personal information under the counsellor’s control, including personal information that is not in the counsellor’s custody, such as personal information that may have been transferred to another professional or organization for review or processing.
Identify the purpose
4. Before or at the time personal information is collected, the counsellor will identify to the client the purpose(s) for which personal information is needed and how it will be used and disclosed.
5. The counsellor will ensure that the collection of personal information is necessary to fulfill the purpose(s) identified and that the purpose(s) is limited to what a reasonable person would consider appropriate in the circumstances.
6. The counsellor will inform the client either verbally, online, or in writing, before or at the time of collection why the personal information is needed and how it will be used, and will answer the client’s questions about the collection of personal information.
7. When using a client’s personal information that has already been collected for a new purpose not previously identified, the counsellor will inform the client of the new purpose and obtain consent prior to its use.
8. The counsellor will obtain consent from the client whose personal information is collected, used or disclosed, and obtain that consent before or at the time of collection, as well as when a new use is identified.
9. When determining what form of consent will be used (e.g., written, verbal, online, implied, opt-in or opt-out), the counsellor will consider both the sensitivity of the personal information and what a reasonable person would expect and consider appropriate in the circumstances.
10. When obtaining expressed consent, the counsellor will inform the client of the purposes for the collection, use or disclosure of personal information in a manner that is clear and can be reasonably understood.
11. If a client is enrolled or covered under an insurance, pension, benefit or similar plan, the client is deemed under PIPA to consent to the collection, use or disclosure of personal information for the purpose of his or her enrolment and coverage under that plan, and in such situations the counsellor will identify the need for and scope of the collection, use or disclosure for the purposes of confirming entitlements and providing payments under the plan.
12. The counsellor will not obtain consent by deceptive means or by providing false or misleading information about how the personal information will be used or disclosed.
13. The counsellor will not make consent a condition for supplying a product or a service unless the collection, use or disclosure of the personal information is necessary to provide the product or service.
14. Should a client wish to withdraw consent, the counsellor will explain the likely consequences of withdrawing consent.
15. The counsellor will not prohibit a client from withdrawing consent to the collection, use or disclosure of personal information unless it would frustrate the performance of a legal obligation.
16. The counsellor will collect personal information for purposes that a reasonable person would consider appropriate in the circumstances, and will ensure the amount and type of personal information collected is necessary to fulfill the identified purposes.
17. Before or at the time of collection, the counsellor will comply with the previous two policies by informing the client of the purposes for collection and obtaining consent.
18. The counsellor will collect client personal information directly from the client, unless the PIPA or the client authorizes the collection of personal information from another source.
Use, disclosure and retention
19. The counsellor will use or disclose personal information only for the purpose(s) for which it was collected, unless the client consents to the new purpose, or the use or disclosure is otherwise authorized by the PIPA.
20. The counsellor will use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances.
21. The counsellor will keep personal information only as long as necessary to fulfill the purpose(s) for which it was collected, but will keep personal information that is used to make a decision about an individual for at least one year after using it so the individual has a reasonable opportunity to obtain access to it.
22. The counsellor will destroy, erase or render anonymous personal information as soon as it is no longer serving the purpose for which it was collected and is no longer necessary for a legal or business purpose.
23. The counsellor will minimize the possibility of using incorrect or incomplete information when making a decision that affects a client or when disclosing a client’s information to another professional or organization by making reasonable efforts to ensure that the personal information the counsellor collects is accurate and complete.
24. The counsellor will make reasonable security arrangements to protect personal information in its custody or under the counsellor’s control, which will include physical measures, technical tools, and organizational controls where appropriate.
25. The counsellor will safeguard personal information from unauthorized access, collection, use, disclosure, copying, modification or disposal, and will protect personal information regardless of the format in which it is held (e.g., paper, electronic, audio, video).
26. The counsellor is the person who is accountable for these personal information policies and procedures, and is the person who can answer questions about the purposes for collecting personal information and the application of these policies and procedures.
Access and Corrections
27. On request, the counsellor will provide a client with access to their personal information, an explanation of how the client’s personal information is or has been used, and a list of any individual or organization to whom that personal information has been disclosed.
28. The counsellor will provide a copy of the information requested or a response that includes reasons for not providing access, subject to the exceptions set out in the PIPA, within 30 business days unless an extension of time is permitted under the Act.
29. The counsellor may charge the client reasonable fees for the purposes of providing the client access to or a copy of the client’s personal information, but will not charge the client a fee for correction requests.
30. If all or part of the requested information is refused, the counsellor will provide the applicant client with a response that provides the reasons and the provision of the PIPA on which the refusal is based, and information on how to request a review by the Privacy Commissioner.
31. On request, the counsellor will correct personal information that the counsellor verifies is inaccurate or incomplete.
32. If a correction is made, the counsellor will send a copy of the corrected personal information to each person or organization to which the incorrect or incomplete information was disclosed in the past year.
33. If no correction is made in response to an individual’s request, the counsellor will annotate the personal information in (i.e., make a note) to indicate that a correction was requested but not made.
34. If a client has a concern for the manner in which a counsellor collects, uses or discloses that client’s personal information, the client should so advise the counsellor of that concern in writing, online, or orally if the counsellor so agrees.
35. The counsellor will (a) document the date the client’s concern was received and promptly acknowledge receipt of the complaint; (b) investigate the concern in a fair, impartial and confidential fashion, including clarifying any details with the client about the concern; (c) if necessary, take appropriate measures to correct the counsellor’s information handling policies or procedures; (d) report back to the client in writing with the results of the investigation or corrective action; (e) advise the client of the right to file a complaint with the BCACC.
36. If the client is not satisfied with the counsellor’s response, the client may file a complaint against the counsellor with the BC Association of Clinical Counsellors, by writing to the Chair, BCACC Inquiry Committee, #14 – 2544 Dunlevy Street, Victoria, British Columbia V8R 5Z2.
37. If the client is not satisfied with the BCACC’s response to the complaint, the client may file a further complaint against the counsellor with the BC Privacy Commissioner at P.P. Box #9038, Stn. Prov. Govt., Victoria, British Columbia V8W 9A4.
If at any time you believe that My Therapy has not adhered to these principles, please contact:
Contact Person: Lorraine Irlam
E-mail Address: lorraine@MyTherapyOnline.ca
After attempting to resolve your concern with us directly, if you are still not satisfied and feel you must report an ethical breach to our professional organization, you may do so through the web site of the BC Association of Clinical Counsellors.
Adoption by the counsellor
I, Lorraine Janet Irlam, on the 22nd of March, 2013, hereby declare that I will conduct my clinical practice in accordance with these policies and procedures, and the requirements of the Personal Information Protection Act.